Supreme Court Expands Definition of “Degree” for Food Safety Officer Qualifications

I. Introduction

The Supreme Court of India, in the matter of Chandra Shekhar Singh & Others v. The State of Jharkhand & Others (2025 INSC 372), addressed an important employment dispute concerning the qualifications required for appointment as Food Safety Officers (FSOs). The appellants, who held Master’s degrees in subjects such as Microbiology and Food Science & Technology, challenged the state’s refusal to consider them eligible on grounds that the concerned notification and recruitment rules allegedly required a Bachelor’s degree in specific subjects.

This commentary provides an in-depth examination of the Judgment’s background, the legal questions involved, the Supreme Court’s holdings on the meaning of “degree,” and the Judgment’s broader impact on the interpretation of statutory rules. The case is significant for clarifying that the term “degree” in the relevant rule encompasses Bachelor’s, Master’s, and Doctorate qualifications, with only a focused exception for the subject of Chemistry.

II. Summary of the Judgment

The Supreme Court allowed the appeal filed by Chandra Shekhar Singh and others. It found that the term “degree,” as used in the Food Safety and Standards (FSS) Rules, 2011 and in the subject advertisement, was not restricted exclusively to a Bachelor’s degree in the specified fields such as Food Technology, Dairy Technology, Biotechnology, etc. Instead, it included higher degrees such as a Master’s or Doctorate. The sole distinction made was in the case of Chemistry, where a Master’s degree or higher qualification is specifically required.

The Court held that the appellants, possessing Master’s degrees in subjects such as Microbiology and Food Science & Technology, were indeed qualified under the relevant rules. The earlier findings by the High Court of Jharkhand, which had disqualified these candidates, were set aside. To ensure justice, the Supreme Court directed that the appellants be allowed to participate in the interview stage, either by using any existing vacancies from the 2016 recruitment process or by creating supernumerary posts if those vacancies no longer existed.

III. Analysis

A. Precedents Cited

The Judgment made reference to the earlier Supreme Court precedent of Parvaiz Ahmad Parry v. State Of Jammu and Kashmir and Others (2015) 17 SCC 709. In Parvaiz Ahmad Parry, the Court ruled that a candidate possessing a higher degree in the requisite subject could not be disqualified simply because the advertisement explicitly mentioned a lower-level degree (e.g., a Bachelor’s degree). This precedent guided the Court’s decision here, reinforcing the principle that “degree” should be interpreted to include academic achievements at a higher level in the same or closely allied subject unless expressly excluded.

B. Legal Reasoning

The crux of the Supreme Court’s reasoning lies in its interpretation of the relevant sections of the Food Safety and Standards Act (FSS Act), 2006, particularly Sections 37, 91, and 94. These provisions empower the Central Government to prescribe qualifications for Food Safety Officers, while the State Government’s role is limited to the appointment process and cannot override centrally prescribed educational criteria.

The Food Safety and Standards Rules, 2011 (“FSS 2011 Rules”), framed by the Central Government, specify that a candidate must have a “degree” in Food Technology, Dairy Technology, Biotechnology, Oil Technology, Agricultural Science, Veterinary Sciences, Biochemistry, or Microbiology—or a Master’s degree in Chemistry—alongside other requirements. The Court reasoned that Section 22(3) of the University Grants Commission (UGC) Act, 1956, clarifies that “degree” encompasses Bachelor’s, Master’s, and Doctorate degrees. Therefore, refusing to recognize an appellant’s Master’s degree or Doctorate in one of the relevant subjects would be illogical and contrary to the statutory framework.

Furthermore, the Court noted that the 2022 Amendment to the FSS Rules explicitly recognized that “degree” means Bachelor’s, Master’s, or Doctorate degrees across the specified subjects, thereby removing any confusion. In other words, the Court achieved a harmonious reading of the statute and subordinate legislation, ensuring that candidates with more advanced knowledge are not arbitrarily disqualified.

C. Impact

The ramifications of this Judgment are twofold. First, it ensures a broader talent pool for Food Safety Officers across the country. Qualified individuals with advanced degrees in relevant fields—such as Microbiology, Biochemistry, and Food Technology—can now be considered without any artificial barrier created by a narrow reading of “degree.”

Second, the decision underscores the supremacy of the Central Government’s rules and clarifies that state authorities must align their recruitment processes with these rules, rather than unilaterally impose further restrictions. This will likely influence future recruitment notifications and reduce litigation arising from misinterpretation of educational requirements. It also provides clarity to candidates seeking public employment in specialized fields, preventing confusion about whether higher-level degrees can substitute for or exceed the minimum Bachelor-level requirement.

IV. Complex Concepts Simplified

Below are some of the key legal concepts clarified in simpler terms:

Concurrent List (Seventh Schedule): In India’s Constitution, subjects mentioned in the Concurrent List can be legislated upon by both the Parliament and State Legislatures. Food safety falls under this list, but laws enacted by Parliament (i.e., central legislation) will prevail in case of any conflict.
Prescribing Qualifications: The FSS Act empowers only the Central Government to prescribe qualifications for Food Safety Officers. A state might appoint suitable personnel, but it must adhere to the criteria established by central rules.
Definition of “Degree”: Under Section 22(3) of the University Grants Commission Act, 1956, a “degree” includes a Bachelor’s, Master’s, or Doctorate degree. Consequently, unless explicitly stated otherwise, a Master’s or Doctorate degree in the requisite subject is valid if the rule or advertisement merely says “degree.”
Golden Rule of Interpretation: This principle suggests that words in a statute should be read in their ordinary sense unless such reading leads to an absurd result. The Court highlighted that excluding higher degrees from the definition of “degree” would be illogical.

V. Conclusion

In Chandra Shekhar Singh v. State of Jharkhand, the Supreme Court definitively clarified that a reference to “degree” in the Food Safety Officer qualification criteria must be interpreted broadly to include Bachelor’s, Master’s, or Doctorate degrees, except where the rules explicitly specify a Master’s for particular subjects (i.e., Chemistry). This ruling not only provides relief to the appellants, who hold advanced degrees in Microbiology and Food Science & Technology, but also establishes a vital precedent for future recruitments across the nation.

The Court’s directive to create supernumerary positions if no current vacancies exist ensures justice for these appellants while safeguarding the seniority of those already appointed. Moreover, by clearly demarcating the powers of the Central and State Governments, the Judgment prevents confusion or conflict in future recruitment processes.

Ultimately, this decision upholds both fairness and legislative intent, ensuring that all suitably competent individuals can contribute to the critical functions of food safety and standards enforcement.